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From: Jan Kriezl M Catipay on behalf of Josenilo G Mendoza

Sent: Thursday, August 18, 2016 6:51 PM


To: RACELIS RUSSELL - NCFL
Cc: aoki.kenji@nidec.com; DECASTRO VILMA - NCFL; janelyn.aniciete@nidec.com; Jan Kriezl M Catipay;
Iris Dawn O Pepito; Karla Kathrina D Balita; Melissa Anne C Boco; Lanie Grace S Lim
Subject: RE: Inquiry for the deadline of Submission of TIMTA

Dear Russell,

This is in reply to your query on the submission deadline of the Annual Incentives Tax Reports for Income Tax and VAT for
the Fiscal Year ending March 2016 of Nidec Philippines Corporation (“the Company”).

We reply.

PEZA Memorandum Order No. 2016-003 provides that the Annual Tax Incentives Report for income based tax incentives
(Annex A.1) which shall be submitted on September 15, 2016 shall cover any and all taxable years ending in any month of
2015 (i.e., from Taxable Year ending January 31, 2015 until Taxable Year ending December 31, 2015). Moreover, for the
Annual Tax Incentives Report on VAT, Excise Tax and Duty-Based Incentives (Annex A.2), the coverage shall be during the
calendar Year 2015.

Thus, since the Company’s fiscal year ended only in March 2016, it appears that for both annexes, the Company does not
fall under the submission deadline on September 15, 2016. There is no explicit mention on the deadline of submission for
companies ending in any month of fiscal year 2016. The June 14, 2017 deadline indicated in the memorandum order refers
to the deadline of submission of the Consolidated Annual Tax Incentives Report by the IPAs (e.g., PEZA) to the BIR (60
days from the deadline of filing the Final Adjustment Return). This is also consistent with the provision under DOF-DTI Joint
Memorandum Order No. 1-2016, the IRR of TIMTA.

We made an informal inquiry with Mr. Chino Flores of PEZA’s Incentives Department. As per Mr. Chino Flores, the issuance
is only applicable for the submission of Annual Incentives Tax Reports for the year 2015, as mentioned, the deadline for
submission of which is on September 15, 2016.

Moreover, as represented, PEZA will be issuing a new memorandum clarifying the submission deadline of the Annual
Incentives Tax Reports for companies whose taxable year ends in any month of 2016. He further advised that the
Companies wait for such new issuance before submitting its Annual Incentives Tax Reports for FY 2016.

We will let you know further should the new memorandum be issued by PEZA.

We hope the foregoing meets your requirements. If you have further concerns, please do not hesitate to contact us.

Regards,
Nilo

Josenilo G Mendoza | Partner | Tax


SGV & Co.
6760 Ayala Avenue, 1226, Makati City, Philippines
Office: +632 878 7902 | Cell: +63918 878 7902 | Josenilo.G.Mendoza@ph.ey.com
Website: http://www.ey.com

In providing our comments in this communication, we have relied upon our understanding of current Philippine tax laws, regulations, rules, and issuances of the relevant tax
authorities as of this date. Should these laws, regulations, rules, and issuances change, some of the issues/conclusions discussed in this communication may change as well. We will
not be responsible for updating the information herein, unless we are specifically requested to do so.

This communication is solely for your needs and is not to be relied upon by any other person or entity (other than the tax authorities). Hence, if you wish to disclose copies of this
communication to any other person or entity, you must inform them that they may not rely upon our work for any purpose without our written consent.

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Any U.S. tax advice contained in the body of the e-mail was not intended or written to be used, and cannot be used, by the recipient for the purpose of avoiding penalties that may be
imposed under the Internal Revenue Code or applicable state or local tax law provisions.

From: RACELIS RUSSELL - NCFL <russell.racelis@nidec.com>


Sent: Wednesday, August 17, 2016 8:43:16 AM
To: Josenilo G Mendoza
Subject: Inquiry for the deadline of Submission of TIMTA

Dear Sir Nilo,

As regards the submission of TIMTA, can I confirm if the Nidec Philippines Corporation's submission of all the
required documents for TIMTA is on June 14, 2017?

As underlined in your e-mail to Mr. Aoki that the September 15, 2016 deadline covers taxable years ending in any
month of 2015; page 3 of the PEZA MO also states likewise, that 'For taxable year 2016 and onwards, the
deadline for submission of these reports shall be June 14 of the following year.'

Thank you, Sir.

Regards
,

RUSSELL N. RACELIS

Nidec Philippines Corporation Tel: (049)541-1111


Accounting & Finance Division Fax: (049)541-1671
136 North Ave., SPEZ, LTI Email: russell.racelis@nidec.com
Biñan, Laguna webside: http;//www.nidec.com

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